In its letter, the CRN outlined its concern for the future of fish oil processing, and said it felt the current process definition was too restrictive and limiting. “There is no need to list steps used to concentrate oils for it could be misconstrued that these are the only steps allowed,” wrote CRN’s Douglas MacKay, N.D., vice president, scientific & regulatory affairs, and James Griffiths, Ph.D., vice president, scientific and international affairs. “The art and science of concentrating oils is always evolving and innovation is an important part of fish oil refining. CRN is concerned that a list of specific steps that can be used to concentrate oil may not cover all methods currently in use, and may hamper future innovation.”

CRN also took issue with a table designed to identify fish oils by their fatty acid profiles. “We are concerned that the source of data for named fish oils cannot be traced to specific fishing zones and years,” the group wrote. “CRN’s concerns stem from the fact that fatty acid profiles are prone to significant fluctuations. Factors that impact fatty acid profiles include geographical waters, food sources, environmental conditions and variations of seasonal fisheries.”

Oxidation parameters were another area challenged by CRN, especially as it related to flavored fish oils. “…added flavors can skew acid and peroxide values and lead to false positive test results for oxidation…therefore, for flavored fish oil, standard testing methodology and limits are not fit-for-purpose,” the group wrote. “However, the Proposed Draft Standard for Fish Oils, as currently written, creates a quality loophole that will allow low-quality fish oils the privilege of not having to meet the standard acid and peroxide values simply by adding flavors.”

In the realm of food additives, contaminants and analytical methods, CRN recommended that each issue be deferred to the respective Codex Committee.

CRN’s comments were issued on the final day of the submission period, which was yesterday.